Real estate privately (box 3) vs. via BV (Vpb)

AspectPrivately (box 3)Via BV (Vpb)
Annual tax on valueBox 3: 36% on deemed return (6% on investments)Vpb: 19% on actual rental income and gains
Tax on rental incomeIncluded in box 3 (actual return)Vpb 19% on net rental income
Tax on value gainBox 3 (actual return)Vpb on gain when sold
Transfer tax (overdrachtsbelasting)10.4% (investment)10.4% (investment)
Mortgage interest deductibleLimited in box 3Yes, as BV cost

Buying in the BV: key consideration

Once real estate is in a BV, extracting it (selling to yourself or to a third party) triggers corporate tax and then box 2 tax. Never put a property in a BV unless you are confident it should stay there long-term. The transaction costs in and out are significant.

When a real estate BV makes sense

  • Portfolio of 5+ properties where the management is a genuine business
  • Commercial real estate held by the operating company for business use
  • Real estate development (buy, renovate, sell) — active business in BV
  • When combined with a holding to enable participation exemption on sale

The transfer tax problem

Transferring existing privately-owned real estate to a BV costs 10.4% transfer tax on the market value. This is a significant one-time cost that makes the switch financially unattractive for most individual properties. Buy new real estate directly via the BV rather than transferring existing property.